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rcra hazardous wastePharmaceutical waste containers help make hazardous waste management easy to manage, but there are many differences between collecting and disposing pharmaceutical waste and biomedical waste.

Pharmaceutical waste regulations can be tricky, and non-compliance can lead to hefty fines! Whether you work in a doctor’s office, a hospital or a clinic, you will need to know which pharmaceutical waste containers to get, and how to use them across your healthcare facility.

Different states have different regulations, and it pays to understand what is acceptable in your state and what is not.

Read on to find out which regulations concerning your pharmaceutical waste containers you need to be complying with to avoid fines.

RCRA-Hazardous Waste and D-Listed Drugs

Some pharmaceutical waste products are hazardous and must be separated before disposal. According to the Resource Conservation and Recovery Act (RCRA), RCRA-hazardous waste requires special and separately labeled pharmaceutical waste containers. These containers are usually black, and in Florida, all D-listed waste goes in there.

Certain substances have specific characteristics that make them toxic, inflammable, corrosive and even explosive. These D-listed pharmaceutical waste have specific packaging and disposal requirements.

Your medical waste disposal provider will identify all such D-listed waste and propose the safest route to dispose and treat such dangerous medical waste.

P-Hazardous Waste

Some medical waste can pose a serious threat to the environment. These P-listed medications include epinephrine and warfarin, and should be properly labeled and carefully shipped.

For such dangerous waste, specific hazardous waste storage areas should be designated to store the pharmaceutical waste containers, and there are strict regulations on tracking their generation.

Facilities are expected to weight and document all P-listed waste on a monthly basis, and depending on the weight of total acutely hazardous produced, a facility can be classified as a large quantity hazardous waste generator.

In Florida, P-Hazardous waste is disposed in black pharmaceutical waste containers.

U-Hazardous Waste

The U-list is another list of especially hazardous materials, which include chemotherapeutic agents and other specialized waste which is dangerous to humans, as well as the environment. You must be well aware if your facility is producing any U-list waste, and if it does so in quantities to qualify as a large quantity hazardous waste generating facility.

As with all specialized waste, U-list waste should be disposed separately and the total output periodically weighted and reported to the authorities. Failure or misreported weights can lead to serious fines!

Chemotherapy Pharmaceutical Waste Containers, ‘trace’ and ‘bulk’

Additionally, chemotherapeutic agents and materials used in chemotherapy can be further classified as ‘trace’ or ‘bulk’, as well as RCRA-hazardous.

While the official term is ‘RCRA-empty’, ‘trace’ is much more commonly used and refers to vials, bags, IV tubes and other items that used to contain chemotherapy drugs. For example, a container that held a P-listed chemotherapy drug can only be classified as ‘trace’ after it has been rinsed three times, and a container that held a U-listed substance is ‘trace’ only after there is less than 3% of its original volume left.

So, many of the aforementioned waste can be ‘downgraded’ to ‘trace’ with the proper handling, otherwise they must be disposed as listed hazardous materials.

Bulk chemotherapy waste refers to items that were used to clean up chemotherapy spills, containers that cannot qualify as RCRA-empty’ and the chemotherapeutical agents themselves, including certain expired chemotherapy drugs.

Keep in mind here that certain expired substances are not immediately classified as bulk waste, and can be returned safely to their manufacturer through one of the many nationwide take-back initiatives.

You should consult with your medical waste disposal expert, or the company that handles your pharmaceutical waste containers about such take-back programs, as they may reduce financial risk for your medical facility.

Regulations for Controlled Substances

All controlled substances, including: morphine, hydrocodone, codeine, diazepam and many others must be transported and handled according to DEA regulations,  which also included specific procedures for their disposal.

While there are no special DEA regulations for the type of pharmaceutical waste container used, the contents themselves are crucial, especially since many controlled substances are also classified as hazardous waste according to hazard classification requirements.

In Florida, regulations forbid the disposal of narcotics in the black waste containers used for all other pharmaceutical waste. Controlled substances must be handled by a reverse distributor.

Eco-Friendly Best Practices for Disposing Pharmaceutical Waste Containers

In many states, including Colorado it’s considered a best practice to dispose non-RCRA-hazardous pharmaceuticals at special facilities that incinerate or otherwise safely recycle the waste and keep it out of drinking water supplies.

According to the California Department of Public Healthnon-RCRA-hazardous waste must be separated from other pharmaceutical waste and incinerated at a waste treatment facility. When it comes to your pharmaceutical waste containers, a simple labeling system can ensure that you are complying with these best practices and environmental regulations enforced by law in certain states, including California.

Depending on the medical facility, medical waste disposal can be simplified with two containers, one for hazardous and one for non-RCRA-hazardous waste. Your medical waste disposal provider will help you decide the simplest, more efficient method to handle and dispose medical waste.

Proper Training

Even the best medical waste disposal system will fail if not adhered to. For that reason, your staff should be specifically trained on how to sort, handle and dispose hazardous and non-RCRA-hazardous waste.

Everyone involved should clearly understand the types of medications and packaging that are considered hazardous and need their own pharmaceutical waste containers.

Also, make sure your staff meets the minimum requirements as set by the regulations.

Enlist the Help of a Qualified Partner

To make sure you adhere to all regulations, you should consult with a reliable company that specializes in medical waste management to obtain a tailor-made checklist for all the waste that is produced in your facility. Such a list will cover all hazardous materials and can be combined with an efficient pharmaceutical waste container system to streamline your disposal and ensure regulatory compliance.

Keep in mind that in Florida, all classifications of pharmaceutical waste can go into the black box, with the exception of narcotics.

Make sure that your medical waste management partner is licensed by the EPA and DOT to transport hazardous waste to disposal facilities, and also check state-specific regulations for special permits and licenses.

Finally, many medical waste management companies also offer consultations and informational materials that can help with training your staff in the implementation of your new pharmaceutical waste container system to overall risk, ensure compliance and make your facility safer for everyone!